The CFTC order finds that the respondents failed to supervise diligently
the manner in which their officers, employees and agents handled the
commodity interest accounts carried by AFG in the Aventura branch, and all
other activities of such persons relating to their business as Commission
registrants. Specifically, AFG, Perk, and Reeves failed to design,
implement, or monitor an appropriate supervision and compliance system in
the Aventura branch.

The order finds that Marchiano failed to establish procedures to
adequately train and supervise the account executives (AEs) in the
Aventura, Florida branch. In addition, he failed to develop a system to
monitor the solicitation of customer business and the trading activity of
the AEs in the Aventura, Florida, branch and he failed to establish
procedures to ensure that customer complaints would be fully
investigated.

Under the Commission's order, AFG, Perk, and Reeves are ordered to pay
$450,000 to be used for restitution to customers. Marchiano is ordered to
withdraw his AP registration and not to re-apply for a period of one year.
After the expiration of this one year time period, should he reapply for
registration, Marchiano may not act as an AP unless he is supervised by a
sponsor for a period of two years. Finally, Marchiano is ordered to pay a
civil monetary penalty of $10,000.

The order settles a two-count CFTC administrative complaint which was
filed on July 31, 1995.